Americans Abroad
US citizens owe US tax on worldwide income regardless of where they live. The Foreign Earned Income Exclusion (FEIE) excludes up to $132,900 of foreign earned income from US income tax for 2026. The Foreign Tax Credit (FTC) provides a dollar-for-dollar credit for foreign taxes paid. Self-employment tax is NOT reduced by the FEIE — this is the trap. FBAR (FinCEN 114) is due by 15 April for foreign accounts exceeding $10,000 aggregate at any point during the year. FATCA (Form 8938) has higher thresholds ($200,000/$400,000 for taxpayers abroad). Renouncing citizenship triggers a potential exit tax under IRC Section 877A if you are a covered expatriate.
TaxKiln Editorial · Last reviewed:
The United States is one of only two countries in the world (the other is Eritrea) that taxes its citizens on worldwide income regardless of where they live. If you are a US citizen or resident alien living in Lisbon, Tokyo, or Dubai, you are required to file a US tax return every year reporting your global income — even if you have not set foot in the US for a decade, even if you pay taxes to your country of residence, and even if all of your income is earned abroad. The IRS provides two primary mechanisms to avoid double taxation — the Foreign Earned Income Exclusion (FEIE) and the Foreign Tax Credit (FTC) — but neither eliminates your filing obligation, and both have traps that catch self-employed Americans abroad harder than anyone else. The single biggest trap: the FEIE excludes foreign earnings from income tax but does not exclude them from self-employment tax. This guide covers every provision that affects Americans abroad, from the FEIE and FTC through FBAR and FATCA reporting to the exit tax on expatriation.
Key mechanics
Worldwide taxation: why Americans abroad must file and the two qualification tests
Under IRC Section 61, gross income means all income from whatever source derived — including income earned outside the United States. Unlike virtually every other developed country, the US does not use a territorial tax system. US citizens and resident aliens are taxed on their worldwide income, period. Living abroad does not change this. Earning exclusively from foreign clients does not change this. Paying taxes to a foreign government does not change this. The filing obligation persists until you are no longer a US citizen or resident alien.
To qualify for the Foreign Earned Income Exclusion, you must meet one of two tests under IRC Section 911(d). The physical presence test requires that you be physically present in a foreign country or countries for at least 330 full days during any 12-month period. The 330 days do not need to be consecutive, and the 12-month period does not need to align with the calendar year — but a "full day" means a complete 24-hour period beginning and ending at midnight. Days spent in transit over international waters do not count. Days spent in the US (even one hour on US soil counts as a US day) do not count. The physical presence test is mechanical and objective — either you were there or you were not.
The bona fide residence test requires that you be a bona fide resident of a foreign country for an uninterrupted period that includes an entire tax year (1 January through 31 December). This is a facts-and-circumstances test that looks at your intent, the nature and duration of your stay, your ties to the foreign country (home, family, bank accounts, social integration), and whether you have a "definite plan" to return to the US. Brief trips to the US do not necessarily break bona fide residence, but extended US stays or maintaining a US home can disqualify you. The bona fide residence test generally provides more flexibility than the physical presence test but requires stronger documentation of foreign ties.
Americans abroad receive an automatic 2-month filing extension (to 15 June) and can request an additional extension to 15 October. However, any tax owed is still due by 15 April — the filing extension does not extend the payment deadline, and interest accrues on unpaid tax from 15 April.
US citizens and resident aliens owe US tax on worldwide income. To claim the FEIE, you must meet the physical presence test (330 days abroad in 12 months) or the bona fide residence test (bona fide foreign resident for a full calendar year). (IRC §61; IRC §911(d)(1); IRC §911(d)(2); Treas. Reg. §1.911-2)
Foreign Earned Income Exclusion and the self-employment tax trap
The FEIE under IRC Section 911(a)(1) allows qualifying taxpayers to exclude up to $132,900 of foreign earned income from US income tax for 2026. The exclusion applies only to earned income — wages, salaries, professional fees, and net self-employment income. It does not apply to passive income (interest, dividends, rental income, capital gains), pension or annuity income, or US government employee pay. The housing exclusion or deduction under Section 911(a)(2) provides additional relief for housing costs above a base amount (16% of the FEIE limit) in high-cost foreign locations, with limits varying by city.
Here is the trap that catches self-employed Americans abroad: the FEIE excludes income from income tax only. It does not exclude self-employment income from self-employment tax. Under IRC Section 1402(a), SE tax is computed on net earnings from self-employment without regard to the Section 911 exclusion. This means a freelancer earning $100,000 abroad who excludes the full amount under the FEIE pays $0 in federal income tax but still owes approximately $14,130 in self-employment tax (15.3% on 92.35% of $100,000). Many Americans abroad are blindsided by this — they assume the FEIE eliminates their entire US tax liability when it only eliminates the income tax portion.
There is one narrow exception: if you are subject to the social security system of a country with which the US has a totalization agreement (31 countries including the UK, Germany, France, Australia, Canada, Japan, and South Korea), and you are covered under that country's system, you may be exempt from US self-employment tax under the agreement. You must obtain a certificate of coverage from the foreign country's social security authority to claim the exemption. Without a totalization agreement (notable absences: Portugal, Brazil, Thailand, Vietnam, most of Central and South America), you owe SE tax to both countries.
The FEIE is claimed on Form 2555, filed with your Form 1040. The election to use the FEIE, once made, remains in effect for all subsequent years unless you revoke it. If you revoke the FEIE, you cannot re-elect it for 5 years without IRS approval. This lock-in rule means the decision to use the FEIE versus the Foreign Tax Credit should be made carefully, with consideration of your expected income trajectory and the foreign tax rates of your country of residence.
The FEIE excludes up to $132,900 of foreign earned income from US income tax, but self-employment tax is still owed on the full amount. Totalization agreements may exempt SE tax in 31 countries. (IRC §911(a); IRC §1402(a); IRC §233 (totalization); Form 2555)
Foreign Tax Credit: the alternative to the FEIE and when it is better
The Foreign Tax Credit under IRC Section 901 provides a dollar-for-dollar credit against US tax for income taxes paid or accrued to a foreign country. Unlike the FEIE, which is an exclusion (reducing taxable income), the FTC is a credit (directly reducing tax liability). For Americans living in countries with income tax rates higher than the US effective rate, the FTC is almost always more beneficial than the FEIE because it can fully eliminate US income tax liability and generate excess credits that can be carried back 1 year or forward 10 years under Section 904(c).
The FTC is subject to a limitation under Section 904(a): the credit cannot exceed the US tax attributable to foreign-source income. The limitation is calculated as: US tax liability multiplied by (foreign-source taxable income divided by worldwide taxable income). This prevents the FTC from offsetting US tax on domestic-source income. For Americans abroad whose income is entirely foreign-source, the limitation is generally not binding unless their foreign tax rate exceeds their US effective rate — in which case the excess credits carry forward.
The choice between the FEIE and FTC is an annual decision with strategic implications. Generally, the FEIE is better when: you live in a low-tax or no-tax country (Dubai, Monaco, the Cayman Islands), your income is below or near the $132,900 exclusion amount, and you want to minimise SE tax (the FEIE does not help with SE tax, but neither does the FTC — this is a wash). The FTC is better when: you live in a high-tax country (most of Western Europe, Japan, Australia), your income exceeds the FEIE limit, or you have significant passive foreign-source income that the FEIE cannot exclude. You cannot use both the FEIE and FTC on the same income — but you can use the FEIE for earned income up to $132,900 and the FTC for income above that amount, or use the FTC for passive income while using the FEIE for earned income.
One critical planning point: if you use the FEIE to exclude $132,900 of income, your remaining US taxable income is taxed starting at the rate that would apply if the excluded income were stacked at the bottom of the brackets. This is the "stacking rule" under Section 911(d)(7) — the excluded income does not disappear from the bracket calculation; it pushes your remaining income into higher brackets. This can make the marginal rate on income above the FEIE threshold higher than expected.
The FTC provides a dollar-for-dollar credit for foreign taxes paid, limited to the US tax on foreign-source income. Better than the FEIE in high-tax countries or for income above $132,900. (IRC §901; IRC §904(a); IRC §904(c); IRC §911(d)(7))
FBAR, FATCA, state tax domicile, and the exit tax on expatriation
Americans abroad face a web of reporting requirements beyond the standard tax return. The Report of Foreign Bank and Financial Accounts (FBAR, FinCEN Form 114) must be filed by any US person who has a financial interest in or signature authority over foreign financial accounts if the aggregate value of all foreign accounts exceeded $10,000 at any time during the calendar year. The $10,000 threshold is for the aggregate of all accounts — if you have three accounts with $4,000 each, you must file. The FBAR is filed electronically through the BSA E-Filing system (not with the IRS) and is due 15 April with an automatic extension to 15 October. Willful failure to file carries penalties of the greater of $100,000 or 50% of the account balance per violation. Non-willful failure carries penalties of up to $10,000 per violation. These penalties are per account, per year — they can be catastrophic.
FATCA (Foreign Account Tax Compliance Act) requires US taxpayers to report specified foreign financial assets on Form 8938 if the total value exceeds certain thresholds. For taxpayers living abroad, the thresholds are higher than for domestic filers: $200,000 on the last day of the year or $300,000 at any time during the year (single), or $400,000/$600,000 (MFJ). Form 8938 covers a broader range of assets than the FBAR — including foreign stocks and securities held outside of a financial account, foreign partnership interests, foreign mutual funds, and certain foreign trusts and estates. FBAR and Form 8938 have overlapping but not identical coverage — you may need to file both.
State tax domicile is a persistent problem for Americans abroad. Some states (notably California, New York, Virginia, New Mexico, and South Carolina) are "sticky" — they continue to assert tax jurisdiction over former residents who have not affirmatively established domicile in another state or country. California, for example, presumes you are still a California resident if you leave but maintain "intangible ties" such as a professional license, voter registration, or bank accounts. California taxes worldwide income of its residents, and the Franchise Tax Board has been known to pursue former residents living abroad for years after they left. The cleanest approach is to establish legal domicile in a no-income-tax state (TX, FL, NV, WA, WY, AK, TN, NH, SD) before moving abroad, or to formally sever all ties with your state of last residence by filing a change-of-domicile declaration if your state accepts one.
Expatriation — formally renouncing US citizenship or abandoning long-term permanent resident status — triggers potential tax consequences under IRC Section 877A. You are a "covered expatriate" if: (1) your average annual net income tax liability for the 5 years before expatriation exceeds $201,000 (2026 estimate, indexed for inflation), (2) your net worth exceeds $2 million on the date of expatriation, or (3) you cannot certify 5 years of tax compliance. A covered expatriate is subject to a mark-to-market exit tax on the net unrealized gain in all worldwide assets, as if all property were sold at fair market value on the day before expatriation. A $966,000 exclusion (2026 estimate) applies to the deemed gain. Deferred compensation and interests in certain trusts are subject to a flat 30% withholding tax on distributions after expatriation. The exit tax is real and substantial for high-net-worth individuals — renouncing citizenship is not a simple tax avoidance strategy.
FBAR is required if foreign accounts exceed $10,000 aggregate at any point. FATCA Form 8938 is required above $200,000/$400,000 for taxpayers abroad. Expatriation triggers a mark-to-market exit tax for covered expatriates. (31 USC §5314 (FBAR); 26 USC §6038D (FATCA); IRC §877A (expatriation); IRC §877A(a)(3))
Action steps
- 1
File your US tax return every year, even if you owe nothing
US citizens abroad must file Form 1040 reporting worldwide income. You receive an automatic 2-month extension to 15 June and can request a further extension to 15 October, but tax owed is due by 15 April. Failure to file can result in penalties, loss of FEIE eligibility (you must make a timely election), and extension of the statute of limitations. If you are behind on filings, use the IRS Streamlined Filing Compliance Procedures for taxpayers abroad — this programme allows you to file 3 years of delinquent returns and 6 years of FBARs without penalties if you certify your non-compliance was non-willful.
- 2
Choose between the FEIE and FTC based on your country's tax rate
If you live in a low-tax or no-tax country, the FEIE is typically better. If you live in a high-tax country (Western Europe, Japan, Australia), the FTC is usually better because it provides a larger offset. Model both scenarios using Form 2555 (FEIE) and Form 1116 (FTC). Remember that revoking the FEIE locks you out for 5 years, so make the decision with a multi-year perspective.
- 3
Pay self-employment tax or verify totalization coverage
If you are self-employed, the FEIE does not reduce your SE tax. Check whether your country of residence has a totalization agreement with the US (31 countries). If it does, and you are covered under the foreign country's social security system, obtain a Certificate of Coverage to claim exemption from US SE tax. If there is no totalization agreement, you owe SE tax to the US on your worldwide self-employment income, even if you also pay social contributions abroad.
- 4
File FBAR and FATCA reports for all foreign financial accounts
If the aggregate value of all your foreign bank accounts, investment accounts, and financial accounts exceeded $10,000 at any time during the year, file FinCEN Form 114 (FBAR) electronically by 15 April (automatic extension to 15 October). If your total specified foreign financial assets exceed $200,000 (single, last day) or $300,000 (single, any time), file Form 8938 with your tax return. Both reports may be required for the same accounts — they are separate obligations to different agencies.
- 5
Sever state tax domicile before or upon departure
If you lived in a state with income tax (especially California, New York, Virginia, New Mexico, or South Carolina), take affirmative steps to change your domicile before moving abroad. Register to vote in a no-income-tax state, change your driver's license, close or transfer state-specific accounts, and file a final part-year resident return with your old state. California and New York will pursue former residents for years if ties remain. Establishing domicile in a no-income-tax state before departing is the cleanest solution.
- 6
Consult a cross-border tax specialist before considering expatriation
Renouncing US citizenship has irreversible tax and legal consequences. The exit tax applies to covered expatriates with net worth above $2 million or high tax liabilities. Beyond taxes, expatriation limits your ability to return to the US (you may need a visa), affects inheritance rights, and cannot be undone. Consult a tax attorney who specialises in expatriation before making any decisions — the planning opportunities available before expatriation (gifting, Roth conversions, timing of gains and losses) can significantly reduce the exit tax.
State variance
California
California is among the most aggressive 'sticky' states. The FTB may classify you as a California resident even after you leave the country if you maintain any ties — professional licenses, bank accounts, property, or return to California for extended visits. California taxes worldwide income at rates up to 13.3%. File a final part-year return and sever all possible ties before departure.
New York
New York audits departing residents aggressively and applies a 'domicile' test that looks at where you maintain your strongest ties. New York requires 548+ days outside NY over any 548-day period AND no more than 90 days in NY during that period to change domicile. Maintaining a New York apartment or home during your time abroad can keep you classified as a New York resident.
Texas
Texas has no state income tax. Establishing Texas domicile before moving abroad eliminates state tax risk entirely. Many Americans abroad use Texas (or Florida, Nevada, Wyoming) as their state of legal domicile specifically for this purpose.
Frequently asked questions
What happens if I miss the April 15 tax deadline?+
Do I need a CPA or can I file my own taxes?+
How do quarterly estimated tax payments work?+
I have not filed US taxes in 5 years since moving abroad. What do I do?+
Can I use the FEIE if I work remotely from the US for part of the year?+
Do I owe US tax on rental income from a property I own abroad?+
What are totalization agreements and which countries have them?+
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